U.S. Supreme Court
Simmons v. Paul, 138 U.S. 439 (1891)
Simmons v. Paul
Submitted January 9, 1891
Decided March 2, 1891
138 U.S. 439
The constitutional provision that full faith and credit shall be given in each state to the judicial proceedings of other states does not preclude inquiry into the jurisdiction of the court in which a judgment is rendered over the subject matter or the parties affected by it, nor into the facts necessary to give such jurisdiction.
In 1872, parish courts in Louisiana were vested with original and exclusive jurisdiction over the administration of vacant and intestate successions. chanroblesvirtualawlibrary
The general principles of probate jurisdiction and practice as settled by a long series of decisions in the state courts and in the courts of the United States are applicable to the powers and proceedings of the parish courts of Louisiana.
The order of the parish court in Louisiana granting letters of administration was a judicial determination of the existence of the necessary facts preliminary to them.
The parish court had unquestionable jurisdiction of the intestate estate or succession of Simmons.
The court directed an inventory of the estate and appointed an administrator in the same order, and the inventory was filed upon the following day. Held that this was a sufficient compliance with the requirements of the Louisiana Code, Art. 1190.
Whether the person appointed administrator by the parish court was or was not the public administrator, who, under the law of Louisiana then in force, was the only person to whom such administration could be committed, was a matter to be considered by the court making the appointment, and its judgment thereon cannot be impeached collaterally.
It was the intent of the Legislature of Louisiana in enacting article 1190 of the code that small successions should be granted without previous notice, and that the settlement of them should be done in as summary a manner as possible.
It is settled in Louisiana that the purchaser at a sale under the order of a probate court, which is a judicial sale, is not bound to look beyond the decree recognizing its necessity; the jurisdiction of the court may be inquired into, but the truth of the record concerning matters within its jurisdiction cannot be disputed.
The judgment of a parish court in Louisiana, within the sphere of its jurisdiction, is binding upon the courts of the several states and of the United States.
A court of equity will not entertain jurisdiction to set aside the granting of letters of administration upon a succession in Louisiana on the ground of fraud, and will not give relief by charging purchasers at a sale made by the administrator under order of the court, and those deriving title from them, as trustees in favor of alleged heirs or representatives of the deceased.
In equity. Decree dismissing the bill. Complainants appealed. The case is stated in the opinion. chanroblesvirtualawlibrary